Linpac Plastics, Inc. - Executive Summary |
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I. EXECUTIVE SUMMARY This Executive Summary comprises the Rule 40 CFR 68.155 of the Clean Air Act as it applies to Linpac Plastics. The Tasks, 1-4 indicate Environmental Engineering Consultants, Inc.'s evaluation of Linpac Plastics' compliance with the stated Rule. 40 CFR Part 68.155(a): Accidental release prevention and emergency response policies; Linpac's Process Safety Management (PSM) Policy requires daily inspections by maintenance mechanics and the Plant Engineer. Butane gas detectors are located in the Butane Storage Tank Area and in the Butane Pump Room. These detectors are connected to a butane detection warning panel with lights and a warning horn, it is also integrated into the fire alarm system. Butane pumps and motors are regularly rotated with their backups to verify proper working order and to allow for scheduled maintenance. The Accidental Release Prevention Plan (ARP) is to call 911 for emergency response, sound the evacuation ala rm and evacuate the building. If possible, the butane emergency shut-off will be activated and the power turned off to the butane motors. Operators will turn their equipment off as they evacuate. Maintenance supervisors and lead operators will provide first aid until paramedics arrive. TASK 1 was to perform a Process Safety Management and Accidental Release Plan (PSM/ARM) Compliance Audit. This compliance audit indicated good overall compliance and excellent results, with no accidents related to the Butane System. We recommend that all procedures be updated with the same format as the "Hazard Communication Plan", and that a "Date of Next Revision Due_____" statement be added to clarify the age of the procedure. 40 CFR Part 68.155(b): Stationary source and regulated substances handled; Linpac Plastics, Inc. is a manufacturer of polystyrene plastic. Linpac sells the polystyrene to clients and also uses it to manufacture various plastic containers, such as egg cartons and "carry out" food containers. Butane is used as a blowing agent in the manufacturing process. Butane is stored on site in an 18,000 gallon tank under pressure. Butane is the only "regulated substance" handled by Linpac Plastics. 40 CFR Part 68.155(c): Worst case release scenario(s) and the alternative release scenario(s); TASK 2 was to perform a review of the hazard assessment elements. An off-site consequence analysis was required to evaluate specific potential release scenarios, with a worst-case scenario and an alternative case for computer modeling. * The worst case release scenario indicated a vapor cloud explosion would have an effect to a distance of 0.2 miles (1000 feet). Our research indicates that three (3) I. EXECUTIVE SUMMARY continued: vacant buildings, four (4) active businesses, and two (2) Sebring Airport Authority maintenance buildings, and the water plant could potentially be affected i n this scenario (Figure 1, Map of 1,000 feet radius). * The Alternative Release Scenario indicated that a vapor cloud fire would have an effect to 0.1 miles (500 feet). The vapor cloud fire scenario could affect one (1) active business, three (3) vacant buildings and the Sebring Airport Authority water plant (Figure 2, Map of 500 feet radius). The residential population and the environmental receptors are not affected by either scenario. Linpac's Administrative Controls and Mitigation Measures include the following: * The butane gas detection sensors, with monitoring system and associated alarm. * A locked gate and the chain link fence enclosing the tank and the unloading station. * Back up pumps and motors. * Explosion-proof equipment. * Gravel has been placed around the tank and the unloading station to dissipate a spill. * Only trained mechanics are allowed to perform mainten ance on the butane system. * Safety procedures are reviewed during Safety Meetings. 40 CFR Part 68.155(d): General accidental release prevention program and chemical-specific prevention steps; The general Accidental Release Prevention Program and Chemical-Specific Prevention Steps are as follows: * Only trained maintenance mechanics are allowed to perform maintenance on the butane system. * All work is reviewed by a supervisor and the Plant Engineer before it is performed to ensure compliance with safety rules and to prevent an accidental release. * In general, all maintenance work related to the butane system is performed using a two-person team to ensure safety compliance and to prevent an accidental release. * A butane trained employee is always present during the unloading process to ensure safety compliance and to prevent an accidental release. * The program complies with safety precautions, monitoring, record keeping, reporting, operator training, vapor recovery, secondary containment, work practices, standard operating procedures modifications as needed, the generation of a "Hot Work Permit", and the OSHA PSM Rule. I. EXECUTIVE SUMMARY continued: TASK 3 was to develop a Detailed Accidental Release Prevention Program. Our review indicated that four areas needed to be addressed to be in full compliance with the regulations. 1. Initiate safety compliance audits. 2. Implement an incident investigation procedure, and 3. Implement an Employee Participation Plan. 4. Perform a design review of compliance with the National Fire Protection Association Codes relevant to the butane system. 40 CFR Part 68.155(e) Five-year accident history; Linpac safety records indicate that there have been no accidents related to the butane system during the last five (5) years. 40 CFR P art 68.155(f) Emergency response program; TASK 4 was to develop an Emergency Response Program. We have chosen to use the 911 emergency phone system as our Emergency Response Program (ERP). The Sebring Regional Airport Volunteer Fire Department is less than one mile away and has been notified of the existence of the butane tank, in compliance with the State Emergency Response Program. The fire department has agreements with fire departments in three surrounding cities (DeSoto City, Lorita and the City of Sebring) to provide assistance when needed. Linpac's ERP identifies only the actions to take until the Fire/Rescue Personnel arrive. 40 CFR Part 68.155(g) Planned changes to improve safety To improve safety at the facility, the following procedures will be implemented: * A portable butane detection monitor will be purchased and utilized. * Evacuation drills will be practiced. * Safety Compliance Audits will be initiat ed. * An Incident Investigation Procedure will be instituted. * Implement an Employee Participation Plan. * Linpac will perform a Design Review of Compliance with the National Fire Protection Association Codes relevant to the butane system. |